Recent decisions: "Don't Mess with Zohan" attorneys' fees; Copyright Act's written memo requirement

The January 19, 2011, edition of Loeb & Loeb's IP/Entertainment Law Weekly Case Update for Motion Picture and Television Networks reports on (and links to) two recent copyright decisions of interest:
  • Cabell v. Sony Pictures Entertainment, in which a federal District Court in New York City awarded the producers of "You Don't Mess with the Zohan" only $1,000 in attorneys fees, because of the plaintiff's financial circumstances, even though the producers defeated the plaintiff's claim that their movie infringed the plaintiff's copyright. 
  • Barefoot Architect, Inc. v. Bunge, in which the Third Circuit Court of Appeals held that the written memorandum that the Copyright Act requires in order to transfer copyright does not have to be contemporaneous in order to validate a prior oral transfer of a copyright, though there must be extrinsic evidence demonstrating that the prior oral transfer actually took place. The case itself is not an entertainment case - it involved an architect - but the issue is one of importance to those in the movie business.